background image
Note: This Treaty may be impacted by the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent BEPS (MLI). MLI impact on Tax Treaties is available with the Orbitax International Tax Research & Compliance Expert.


Income from Immovable Property

(1) Income of a resident of a Contracting State from immovable property (including income from agriculture or forestry) situated in the other Contracting State may be taxed in that other Contracting State.

(2) The term "immovable property", shall have the meaning that it has in accordance with the law of the Contracting State in which the immovable property is situated, in any case the definition shall include the property annexed to immovable property, livestock, equipments used in agriculture and forestry, the rights for which the provisions of land property law are applicable, the usufruct of real estate property, and the rights to variable and fixed payments for the exploitation or the right to exploit mineral deposits and other natural resources, but the ships, boats and aircrafts shall not be considered immovable property.

(3) The provisions of paragraph (1) of this Article shall apply to the income from the use of immovable property directly or renting or exploiting it in any other form.

(4) The provisions of paragraphs (1) and (3) of this Article shall apply to income from immovable property used for the performance of independent personal services.